ML20237A653

Insp Rept 50-285/87-30 on 871102-06.Violation Re Failure to Establish Procedures Per Tech Spec 5.8.1 Noted.Major Areas Inspected:Licensee Corrective Actions in Response to Water Intrusion Into Instrument Air

ML20237A653
Person / Time
Site:	Fort Calhoun
Issue date:	12/03/1987
From:	Boardman J, Gagliardo J, Seidle W, Tapia J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20237A627	List: ML20237A626 ML20237A653
References
50-285-87-30, EA-87-210, NUDOCS 8712150148
Download: ML20237A653 (8)

See also: IR 05000285/1987030

Text

EA 87-210

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APPENDIX

l!.S. NUCLEAR REGULATORY COMMISSION

REGION IV

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NRC Inspection Report: 50-285/87-30 Operating License: DPR-40

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Docket: 50-285

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Licensee: Omaha Public Power District (0 PPD)

1623 Harney Street ,

Omaha, Nebraska 68102 '

Facility Name: Fort Calhoun Station, Unit 1 (FCS)

Inspection At: FCS, Blair, Nebraska l

Inspection Conducted: November 2-6, 1987

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Inspectors: ..

A N/JE[i/

W.C.SeidlegChief,OperationalPrograms Date

Section, Division of Reactor Safety

/* (MW n /So[T'7

J. J.' Boardman, Reactor Inspector, Operational Date '

i Rtograms Section, Division of Reactor Safety '

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J.

D .

_wi

apict, Pr'ojectflingineer, Project

n Is /n

Datd '

ion A, DivisioY of Reactor Projects

Accompanied

By: A. B. Beach, Deputy Director, Division of

Reac or Projects exit interview on

fNovep}ber6,1987

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Approved: / .

)3, 3 /)

J(E.G(gliardo, Chief,OperationsBranch Date f

Division of Reactor Safety I

8712150148 871210

PDR ADDCK 05000285

Inspection Summary

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a PDR

Inspection Conducted November 2-6, 1987 (Report 50-285/87-30)

Area Inspected: Special, unannounced inspection of licensee corrective actions

in response to water intrusion into the Instrument Air System.

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Results: Within the area inspected, one violation was identified (failure to

establish procedures as required by Technical Specification 5.8.1, paragraph 2.c

of this report).

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DETAILS

1. Persons Contacted

Licensee

• R. Andrews, Division Manager, Nuclear Production

• W. Gates, Plant Manager

• S. Gambhir, Section Manager, Generating Station Engineering

• M. Core, Supervisor, Maintenance

• J. Fisicaro, Supervisor, Nuclear Regulatory and Industry Affairs i

• T. Patterson, Manager, Technical Support l

• J.-Gasper, Manager, Administrative and Training Services i

• R. Jaworski, Section Manager, Technical Services  !

K. Miller, Supervisor, Mechanical Maintenance <

• L. Kusek, Supervisor,.0perations

• D. Matthews, Supervisor, Licensing 1

• L. Gundrum, Plant Licensing Engineer

• T. McIvor, Supervisor, Technical ,

R. Mueller, Plant Engineer l

• A. Richard, Manager, Quality Assurance

• M. Eldem, Manager, Mechanical Engineering, Genere',ing

Station Engineering

"G. Roach, Supervisnr

• S. Willret, Supervisor, Administrative Services and Security

M. Ellis, I&C Supervisor

• R. Scofield, Supervisor, Outage Projects

C. Ovici, Senior Engineer

NRC

• B. Beach, Deputy Director, Division of Reactor Projects, Region IV .

• P. Harrell, Senior Resident Inspector l

• T. Reis, Resident Inspector

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• Denotes attenCance at the exit interview on November 6, 1987.

The NRC inspectors also interviewed additional licensee personnel during

the inspection period.

2. Licensee Corrective Action Program for Systems Important te Saf^'*

The NRC inspectors accomplished a performance oriented revit- nt the

licensee's corrective action responses to the events involvit.; ;er in i

the Instrument Air (IA) System occurring on July 6, August 25, and

September 23, 1987, with the following findings (see NRC Inspection

Report 50-285/87-27 for a detailed discussion of these events):

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a. July 6,1987, Event - Introduction of Fire System Water into the

Instrument Air Syste.n as a Result of Inadequate Licensee Procedures ,

for the Testing of a Fire System Deluge Valve

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The NRC inspectors found that for the period of July 6-8, 1987, j

licensee actions to blowdown water from the IA System and to  !

determine the extent and amount of water intrusion were neither 1

accomplished in accordance with approved procedures nor documented

to permit subsequent analysis.

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Interviews and discussions with licensee personnel did not reveal any

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involvement of Shift Technic,al Advisors (STAS) with the actions and

decisions following this event, or the events of August 25 and

September 23, 1987.

No approved procedures were identified which were in effect either at

the time of the event or subsequently that addressed analysis and

corrective actions of abnormal conditionc for systems which are

important to safety.

There was no documentation of Plant Review Committee (PRC)

involvement until August 6, 1987. Discussions with licensee

personnel indicated that at the time of, and subsequent to, the event

the absence of the Plant Manager and the Operations Supervisor

precluded having the quorum required for a PRC meeting. The acting i

plant manager, when interviewed by the NRC inspectors, did not

indicate that he considered the event significant and could not

recall whether he contacted offsite-licensee management, or requested >

offsite technical assistance at the time of the event.

l As discussed in NRC Inspection Roport 50-285/87-27, licensee

l personnel did not take corrective action to determine that the

IA system met its design base dew point of -20 F until late October

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1987. In addition, as determined by subsequent tests, the initial

readings were incorrect. The first two instruments used to determine

dew point were neither in the licensee's metrology program, nor had

calibration stickers. One instrument was used without having

l approved site procedures; the other instrument was apparently not I

designed for measurement of extremely low dew points.

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The above findings reveal weaknesses in the implementation of 4

corrective action.

b. Review of Licensee's Actions After the July 6, 1987, Event to

Determine Operability of Safety-Related Components, the Adequacy of

the Justification for Continued Operation (JCO), and Component

Design Adequacy

The NRC inspectors reviewed equipment operability after the July 6,

1987, event and licensee actions to verify the operability of the

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plant. This review was specifically concerned with the effect of

water on components required to maintain the plant in a safe

condition.

The first step taken in this effort was to review Abnormal Operating

Procedure (A0P) No. 17 " Loss of Instrument Air System." As noted in

item G of Appendix A to Enforcement Action (EA)87-210, which is part

of NRC Inspection Report 50-285/87-27, this procedure was found to

be inadequate in that it did not address the affect.of loss of ~-

instrument air on all safety-related equipment. The results of the

review during this inspection disclosed that the procedure.did not

list all safety-related valves equipped with safety-related air

accumulators (21) and conversely, it contained valves which have air

accumulators not considered to be safety-related (44). The purpose

of this procedure is to describe the actions to be taken following a

complete loss of the IA System. As such, this procedure should have

been utilized when responding to the intrusion of water into the

1A System by identifying-those valves required to maintain the plant

in a safe condition, which may have been adversely affected. After

this identification, the operability of the valves could have been

immediately addressed. As noted in Item B of Appendix A to EA 87-210,

the licensee did not' commence a formal documented program for determining

operability until 3 days after the July 6 event.

In order to assess the impact of water intrusion into the IA System,

it became necessary to generate a list identifying which components

may have been affected. From this list it was learned that there are

78 valves with air accumulators -in the plant and that 34 of these are

safety-related. Of the 34 valves, 21 require air accumulators to

fail-safe and mitigate the consequences of a design basis accident,

while 13 valves require the air accumulator to provide repositioning

of the valve after the accident.

The results of the three formal blowdown programs were then reviewed

with particular attention given to determination of the extent of

migration of the water. For each of the 34 safety-related valves, it

was determined if water was found and if the valve-was tested for

operability by cycling after each phase of blowdown. No failures of

the valves in question were identified during the cycling program.

For those air-operated valves that were not tested, the licensee

issued a JC0 providing assurance that the plant will. continue to

operate safely until-those-remaining valves can be cycled. This

document was reviewed by the NRC inspectors and found to provide a

sufficient and correct explanation for allowing continued operation.

In September 1985 the NRC performed a Safety Systems Outage and

Maintenance Inspection (SSOMI) at Fort Calhoun Station. In response

to a SS0MI finding, OPPD committed to a test program for valves with

air accumulators installed to verify that the air accumulators

functionally met their design basis criteria. OPPD's first steps in

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satisfying their commitment was to determine how many times the ,

valves would be expected to be repositioned and how long the accumulator j

would have to maintain the valve position. It was determined that

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22 valves would be required to function for 1,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> using their

air accumulators after a large break LOCA. In that it is unlikely j

that an accumulator can maintain pressure for such a long period, 1

OPPD has taken the position that modification to the valve operators

or a redefinition of their design functions should be considered.

Pending such action, the licensee issued a JC0 supporting operation

through the next cycle.

The NRC inspectors looked into the determination of the boundary of

the IA System with respect to the statement that the loss of

instrument air alone does not result in any safety function being

compromised.

The NRC inspection focused nn the adequacy of the accumulators,

solenoids, and check valves to perform their intended function. This i

review identified a check valve test program conducted to assure the  !

operability of check valves. It was determined that of the 34 valves

of concern, only 12 have had a check valve operability test. Three

of the 12 check valves tested failed to maintain air pressure. One

of the 3 valves failed twice. This information was not considered in

the generation of the JC0 and is considered an open item (285/8730-01)

pending the revision of the JC0 to incorporate what effect, if any,

the noted failure rate will have on the justification to continue

operation.

On October 29, 1987, during the enforcement conference held in the

NRC Region IV offices, OPPD maintained that by the end of the day on

July 6, full operability had been restored (see pages 1-10 of OPPD j

Letter LIC-87-744 to NRC Region IV Administrator). This conclusion I

appears to be in error based on the following factors: l

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(1) the initial actions only included a generic blowdown of

regulators,

(2) the actions taken by the licensee did not define specific valves

which were important to safety, and

(3) no valves were cycled to verify operability until July 9, 1987.

Operability was ultimately assured as a result of the systematic

thr ee-phase blowdown program. )

c. August 25, 1987, Event - Introduction of Demineralized Water (DW)_

Into the IA System Via an Unapproved Modification Between the DW

and IA Systems in the Water Treatment Room

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Until questioned by the NRC inspectors, licensee personnel had

developed no documented, technically verified scenario adequately

explaining the introduction of DW into the IA System in the water

treatment room. Discussions with different licensee personnel

resulted in apparently conflicting information.

Cause of water intrusion into .the IA System included:

The earlier (estimated as 1980) installation of an unapproved

. modification that allowed interconnection of the DW and

IA Systems. This modification consisted of a solenoid valve, >.

timer, a manually operated IA valve, and clear plastic tubing

which was used to connect the modification. The connection to '

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the DW system was to a port in the wall of the body of CV-86, a

I diaphram valve which was used as a check valve for this

application. Once each day during the DW demineralized

back-wash cycle, the solenoid valve in the modification was

opened for approximately 22 minutes by the timer. During this

22-minute period the DW system pressurized the modification up

to the added IA manual valve, which was closed, but not tagged.

The purpose of this unauthorized modification was not known, and

the person involved with it is deceased. This modification did

not appear on DW or.IA Piping and Instrumentation Drawings (P& ids) ,

according to licensee personnel. The system pressure of tne DW i

system was approximately 109 psig; that of the IA System was

approximately 101 psig. As a result, the actual interconnection

of the DW and IA Systems would result in intrusion of DW at a

rate of about 0.09 gpm. When drain valves in the IA System were .

open with the DW/IA systems interconnected, the intrusion rate l

could increase to approximately 0.7 gpm.

After accomplishment on August 24, 1987, of corrective

maintenance (replacement of a section of clear plastic tubing

which was leaking) on the unauthorized modification, a

maintenance mechanic opened the previously closed (but untagged)

manually operated IA valve which had isolated the DW system from

the IA System during previous back-flush cycles. Since the DW

system was not in the demineralized back-flush cycle, water did

not flow from the DW system into the IA System at that time.

During the next demineralized back-flush cycle, shortly after

midnight on August 25, 1987, the solenoid valve in the

modification opened causing DW intrusion into the IA System.

The NRC inspectors found that the licensee had no documented

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safety-related, valve, damper, switch, circuit breaker, or other

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control device by maintenance personnel without specific approval.

Fort Calhoun Station TS 5.8.1 requires that procedures be

established, implemented, and maintained that meet or exceed the

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minimum requirements of ANSI N18.7-1972, Sections 5.1 and 5.3, and

Appendix A of Regulatory Guide 1.33.

ANSI N18.7-1972, Section 5.1.6.1, requires that maintenance which can

affect the performance of safety-related equipment shall be in

accordance with written procedures; Section 5.3.5(3), under

post-maintenance return to service, requires that instructions shall i

be included (or referenced) for returning equipment to normal  !

operating status, giving special attention to systems the.t can be

defeated by leaving valves, breakers, or. switches mispositioned.

The licensee's failure to have a written procedure or instruction' to

preclude the mispositioning of valves, breakers, or switches' constitutes-

an apparent violation of the above requirement (285/8730-02).

d. September 23, 1987, Event - Failure of Emergency Diesel

Generator (EDG) No. 2 Cooling System Exhaust Damper to Open Resulting i

in the Shut-Down of EDG No. 2 Due to High Temperature

Licensee personnel stated that the failure of the damper to open was

caused by the restriction of a pilot valve orifice. The restriction

was a tightly adhering annular build-up of foreign matter. This

matter could not be dissolved using acetone, water, nitric acid, or

hydrochloric acid. It was ultimately removed by licensee' personnel

by reaming the orifice. The foreign matter was then disposed of

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of the foreign matter. Data presented to the NRC on October 29, 1987,

indicates that there were previous instances of " plugged orifices."

This is another example of the ineffectiveness of the licersee's

corrective action program to correct and prevent recurrence of

conditions which are adverse to quality.

3. Exit Interview

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The NRC inspectors met with the licensee representatives denoted in. l

paragraph 1 and the NRC resident inspectors at the conclusion of the i

inspection on November 6, 1987. The NRC inspectors summarized the,

purpose, scope, and findings of the inspection.  ;

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